IN THE COURT OF MS ADITI RAO, LD.

MM SOUTH NI
ACT, SAKET
In Ref with:
CC No. 14689/2019
Niraj Singh VERSUS Sanjay
Kumar

APPLICATION UNDER SECTION 311 Cr.P.C ON BEHALF

OF APPLICANT/ACCUSED SANJAY KUMAR.

MOST RESPECTFULLY SHOWETH:

1. That the above said matter is pending before the Hon’ble Court
and fixed for order.
2. That the applicant/accused is innocent person he has not taken
loan from the complainant. But complainant planned a
conspiracy against the applicant/accused along with the
witnesses. And also some forged document has been prepared
by the complainant.
3. That the complainant produce witness No 2 ex secretary of
Saket Bar Association, New Delhi under the pressure of the
counsel of the applicant not feeling normal so he was unable to
cross examine. Therefore counsel of the applicant/accused
person didn’t put any single question to witness No. 2 in cross
examination, Counsel of the applicant/accused only gave few
suggestions to the witness no. 2.
4. That the cross examination of the witness no. 2 is very essential
for just decision.
 5. That the counsel of the applicant/accused didn’t suggest for any
other witness who knows the true facts of the story.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court

may kindly be pleased to recall the witness no. 2 for cross-
examination in the interest of just decision.

Through

Counsel

PANKAJ KUMAR. SHARMA

CH. NO. 456 LAWYERS BLOCK
Date:- DISTT. COURT COMPLEX
Place:- Delhi SAKET,NEW DELHI-110017